ML18065A489
| ML18065A489 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/06/1996 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18065A490 | List: |
| References | |
| NUDOCS 9602150197 | |
| Download: ML18065A489 (4) | |
Text
consumers Power POW ERi Nii MICHlliAN"S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 February 6, 1996 US Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
TECHNICAL SPECIFICATION CHANGE REQUEST - REMOVE CROSS-TRAIN TESTING REQUIREMENTS FROM LCO ACTION STATEMENTS A request for a change to the Palisades Technical Specifications (TS) is enclosed. This change is requested to bring selected LCO Action Statements in the Palisades TS into conformance with the Standard Technical Specifications (STS) and NRC guidance discussed in an internal NRC memo dated April 10, 1992 from Christopher I. Grimes to Robert A. Capra, et al. Prompt NRC review and approval are requested.
TS 3.3, Emergency Core Cooling System, and TS 3.4, Containment Cooling, require that prior to initiating repairs of selected components, the component which performs a duplicate or redundant function must be tested to demonstrate operability. This requirement applies even when the duplicate or redundant component is in another train. While it is prudent to assure that the funGtion performed by an out-of-service component is preserved, the verification that redundant equipment remains operable can be accomplished through means other than actual equipment testing. In some cases the act of testing redundant equipment can render that equipment inoperable, disabling the very function that the test is intended to preserve. Component testing under these conditions is not in the best interests of safety. This TS change request 9602150197 960206 PDR ADOCK 05000255 P
PDR A OW!fi ~COMPANY
does not relax any requirements for equipment operability; it would merely allow the operability of required equipment to be assured through means other than actual test.
2 It is requested that this change be processed promptly to reduce the potential for future plant shutdowns. A recent event exemplifies the problem that the cross-train testing requirements can cause. On January 3, 1996, with the plant operating at power, a manual header blowdown valve in an air system serving one train of ECCS failed in the open position. The failed valve caused the air system to be declared inoperable along.
with its supplied components, including the air-operated containment sump outlet valve and the Safety Injection and Refueling Water Tank (SIRWT) outlet valve for that train.
This invoked the TS 3.3.2 f requirement to test the equivalent valves in the alternate ECCS train. Testing the alternate train valves was imprudent and potentially detrimental to safety however, because the test would have rendered inoperable, albeit briefly, the entire alternate train. Stroking the containment sump and SIRWT outlet valves is not normally permitted during plant operation, and having either valve out of its normal position constitutes entry into TS 3.0.3. Therefore, in this event and after notifying the Senior Resident Inspector, the air system header was depressurized and a temporary repair was performed to restore air system pressure boundary integrity without testing the duplicate valves in the alternate train. This event was the subject of Licensee Event Report 96-001. (Subsequently, shortly after this event, the plant was placed in cold shutdown for an unrelated reason and the permanent repair implemented without creating another challenge under TS 3.3.2 f.)
Palisades is developing a comprehensive change request to convert our custom TS to emulate Standard Technical Specifications for Combustion Engineering Plants, NUREG 1432 (STS). This comprehensive request is scheduled for submittal by April 1, 1996 and implementation in 1997. With the conversion to STS, the requirement to demonstrate operability of redundant equipment by test will be eliminated from TS because it has been deleted from STS.
In view of the potential for similar problems during operation in the near future, however, action is warranted now to remove this requirement for cross-train testing rather than continuing to wait for the STS conversion. This TS change in conjunction with another submitted on December 27, 1995 corrects all TS sections in which this requirement exists.
Two attachments to the enclosure have been included. Attachment 1 to the enclosure contains the proposed TS pages. Attachment 2 of the enclosure provides the existing TS pages marked to show.the proposed changes.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
Richard W Smedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosure 3
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this Technical Specifications Change Request to remove cross-train testing requirements form LCO action statements, are truthful and complete.
Byp~lS Richard W Smedley Manager, Licensing Sworn and subscribed to before me this~ day of~
1996.
~'W),\\0~
Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires August 26, 1999
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